White Paper

The Time is Now to Overhaul the Bank Secrecy Act (BSA): The BSA Should Facilitate the Generation of Actionable Information and Interbank Collaboration

By Chris Swecker, Financial Crimes Consultant and former Assistant Director, FBI

“The goals of the BSA of generating actionable information regarding significant illicit activity that meets the priorities and threshold loss levels that match modern day crime and CT challenges are an unfulfilled vision, not a current reality.”

In his new white paper The Time is Now to Overhaul the Bank Secrecy Act (BSA): The BSA Should Facilitate the Generation of Actionable Information and Interbank Collaboration Chris Swecker, former Assistant Director of the FBI makes a compelling argument that “Initiating or significantly enhancing a full investigation based on a SAR filing was, and still is, the pinnacle of the SAR program.”

Swecker opines that to fulfill the most important purpose of the BSA, a redesigned SAR system must be at the top of the list. He discusses several recommendations to facilitate the research and production of significant SARs and states that “FIs must be incentivized and even credited when they collaborate to generate “super SARs” that federal agencies can use to initiate and significantly enhance priority investigations.”

Author

Chris Swecker

Financial Crimes Consultant and Attorney
Assistant Director, FBI (retired)
former Global Security Director, Bank of America

Chris Swecker has 30 years of experience in law enforcement, national security, legal, and corporate security/risk management. Swecker served 24 years with the Federal Bureau of Investigation (FBI) before retiring as Assistant Director of the FBI’s Criminal Investigative Division. He was responsible for eight FBI divisions including Cyber, Criminal, International Operations, Training, Crisis Management, Operational Technology, Criminal Justice Information and the Law Enforcement Liaison office encompassing more than half of the FBI’s total resources. Swecker also served as the FBI’s On Scene Commander in Iraq in 2003 where he led a team of FBI Agents conducting counter-intelligence and terrorism investigations.

Tagged as...

  •   314(b) Information Sharing
  •   BSA/AML Compliance
  •   Cross-Institutional AML Analysis
  •   Law Enforcement
  •   Money Laundering
  •   SARs

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